Interpretation ID: nht71-5.42

DATE: 10/14/71

FROM: E. T. DRIVER -- NHTSA; SIGNATURE BY CHARLES A. BAKER

TO: Cox Tire Machinery Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of September 29, 1971, to the National Highway Traffic Safety Administration requesting an interpretation of Federal Motor Vehicle Safety Standard No. 117, has been referred to this office for reply.

Within S5 of Standard No. 117, it states that retreaded tires must conform to S4.2.1 of Standard No. 109. S4.2.1 of Standard No. 109 requires a treadwear indicator that will provide a visual indication that the tire has worn to a tread depth of 1/16 inch. For your information, we have enclosed copies of Standards No. 109 and No. 117.

ENCLS.

COX Fire Machinery Company, Inc.

SEPTEMBER 29, 1971

Highway Safety Bureau Federal Highway Administration

Gentlemen:

Our company is engaged in the sale of retreading equipment and in this business we are constantly calling on tire dealers. A number of our customers have asked whether after retreading standards go into effect will wear indicators be necessary in retreaded tires.

I would appreciate an interpetation of the MVSS 117 in this regard.

Yours very truly,

J. T. Flynt President